Privacy Policy

Conexus Financial Pty Ltd [ABN 51 120 292 257], (referred to as “Conexus”, “us”, “we” or “our”), is committed to protecting the privacy of the personal information that we collect and complying with the Privacy Act 1988(Cth) (“the Privacy Act”) and other applicable international legislation regarding data protection and privacy. This privacy policy (‘Privacy Policy”) applies to all persons who interact with us, including those who are advertisers, subscribers to our goods or services and registered and unregistered users of Conexus services (‘Services”) and your use of all websites owned or operated on behalf of Conexus, including those available via: www.conexusfinancial.com.au,www.professionalplanner.com.au,www.investmentmagazine.com.au and www.top1000funds.com (collectively referred to as “Sites”) This Privacy Policy explains how we handle personal information and the choices available to you regarding collection, process, access, and how to update, correct and delete your personal information. By submitting personal information to us, you agree to our use of your personal information as described herein, so please read this Privacy Policy carefully.

If you are in the European Union or United Kingdom the Controller of your personal data is Conexus Financial Pty Ltd [ABN 51 120 292 257] of Level 3, 1 Bligh Street, Sydney, NSW 2000, Australia.

This privacy policy will not directly address issues surrounding personal information and its collection and use in the course of journalism, but where applicable to its publications, Conexus complies with the Australian Press Council Privacy Standards at http://www.presscouncil.org.au/privacy-principles.

The Sites are not intended for children and we do not knowingly collect data relating to children

1. What is your personal information?

Personal Information includes information or an opinion about an identified individual, or an individual who is reasonably identifiable from the information or opinion. In summary, personal information is any information about you that can be linked to you. It does not include data where identity has been removed (anonymous data)

2. What personal information do we collect and hold?

Personal Information. We collect information through all our Services including digital services subscription, advertising services, events, websites, mobile sites, applications (“apps”), and widgets, competitions and customer surveys (collectively, the “Services”). We collect the personal information needed to provide the Services and for our business operations. The personal information collected, used stored or transferred may consist of your name, address, telephone number, email address, job information, user name, unique site access id, login data , browser type and version, time zone and location, operating system and device you use to access the contact information, job applications if you are seeking employment, details of services you have used or enquired about, or profile data ( username password, your interests , preferences feedback and survey responses) and marketing and communication data preferences in receiving marketing and other information.

Sensitive Information. Sensitive information is a specific category of personal information. Such information includes information related to racial or ethnic origin, religion or other beliefs, membership of a trade union or a profession or trade association, health information, biometric data, criminal record and the like. We do not usually collect sensitive information about you and If we do, we will get your specific consent prior to the collection and use of this information. We ask that you do not send us, and you do not disclose, any sensitive personal information on or through our Services, or otherwise, unless expressly requested.

We collect some information that is anonymous data, if it is linked to you it will be treated as personal information

3. How do we collect and hold your personal information?

We collect your personal information directly from you or via the Sites, in order for you to use our Services unless it is unreasonable or impracticable to do so.

Where we collect personal information, we will only process it to:

perform a contract with you, or

where we have legitimate interests to process the data and they are not overridden by your rights, or

in accordance with a legal obligation, or

where we have your consent.

If you do not wish to provide personal information to us, then you do not have to do so, however, it may affect your use of the Sites or any products and Services offered on it.

If you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time and if you have not provided express consent you can object to our data processing. Please see Section 9 Your Rights. Please be aware, however, that in some circumstances the withdrawal of your consent or objection may result in our also not being able to provide some services to you.

4. What information do we collect?

Registration Information is the information you provide to us in the course of registering for or acquiring our Services, for example, to create an account, become a subscriber, become an advertiser, post comments, receive a newsletter, attend an event or enter a competition. Where possible, as required by law, you may have the option of interacting with us anonymously (for example when browsing our digital products as a casual user) or using a pseudonym. We will usually make it clear whenever this is an option.

Public Information and Posts consist of comments or content that you post to the Services and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, tweets, status, profile information and picture(s). Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.

Information from Third Party Social Media. If you access or log-in to our Services through a third party social media service, or connect our Services to a third party social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the third party social media service to share with us, such as your profile picture, email address, followers or friends lists, and any information you have disclosed in connection with that social media service.

Activity Information – Cookies and Other Technologies. Our website uses Cookies so when you access and interact with our Sites and Services, we may collect certain information about those visits. For more information please refer to our Cookie Policy

Information from Other Sources. We may supplement the information we collect for legitimate business and commercial purposes with solicited personal information from other sources, such as commercially available sources, websites and data providers, as well as information from our business partners or affiliated companies in Australia or internationally.

Information in relation to employment/engagement with us. When you apply for a job or contract with us we may collect certain information from you or from any recruitment consultant, your previous employers and others who may be able to provide information to assist us in deciding whether or not to make you an offer of employment or engage you under a contract. We also collect personal information about individuals who are, or are employed by, our suppliers (including service and content providers), contractors, dealers, agents and corporate customers.

Collection of Personal Financial Information by a Payment Service. In some cases, we use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this privacy policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

Linked Services. The Sites and Services may also be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, newsletters, competitions or applications developed and maintained by unaffiliated companies. We are not responsible for the privacy practices of unaffiliated companies, and once you leave the Conexus Services or click an advertisement you should check the applicable privacy policy of the other service

5. How do we use your personal information?

To provide our Services. We use the information we collect from and about you for primary purpose of providing our Services and features to you, including:

to fulfil necessary administrative functions associated with these Services (for example billing, credit and account management) and to provide you with customer support and to respond to inquiries;

to enter into contracts with you or third parties and for marketing and client relationship purposes;

to measure and improve your experience with both online and off-line Services through research and data analysis by us and our service providers, to deliver content we believe you are likely to find relevant and interesting, including advertising and marketing messages;

where your information is contained within an advertisement which we publish for you, we may also use your information for publication of that same advertisement in other media, in accordance with the terms and conditions applicable to the initial publication of the advertisement;

to allow you to comment on content and participate in surveys or competitions. If you are a competition winner, we may disclose your information to relevant regulatory authorities and publish your details in accordance with the competition terms;

to allow social sharing functionality. If you log in with or connect a social media service account with the Services and your personal information is contained in a user generated post or in a communication to an editor or journalist. if we choose to publish comment/correspondence in any media, we may share your user name, picture, tweets and likes, as well as your activities and comments with other Services users and with your friends associated with your social media service. We may also share the same information with the social media service provider and the use of that shared information will be governed by the social media service’s privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your Services account and do not participate in social sharing on the Services. If you have linked any of your social media accounts to your account for any Services, you can cancel that link by changing your account settings.

To allow service and content providers to assist us in providing and managing the Services. We may make your information available to certain third-party service and content providers, such as providers of data cloud services, website hosting service providers, debt collection services and direct marketing services, who help us manage or provide the Services. We require these service and content providers to comply with relevant privacy and data protection laws and not to use personal information which we provide for any purpose other than the specific service they are providing to you and/or us. The Sites are hosted by Flywheel an American company within a secure Singapore data centre. We use a number of other third parties to also process personal information on our behalf. These third parties have been carefully chosen and all of them comply with relevant privacy and data protection laws. These third parties are mostly based in the USA and are U. S Privacy Shield compliant.

To provide co-branded services and features. We may offer co-branded services or features, such as competitions or other promotions together with a third party (“Co-Branded Services”). These Co-Branded Services may be hosted on the Services or on the third party’s service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party’s use of your information will be governed by the third party’s privacy policy. We will advise you when this is occurring, or obtain your express consent to share your personal information in these circumstances.

To deliver relevant advertisements. We and our advertisers may use the information we collect from and about you to deliver relevant ads to you when you use the Services or another service. Most advertising is delivered using Google DoubleClick and by using these services, third-party vendors, including Google, may show our ads on sites across the Internet. If you wish to obtain more information about how your previous usage of the Internet may be used to determine the ads that you see when you use the Services, go to Cookie Policy

To contact you. We may periodically send promotional materials or notifications which we believe might be of interest to you. Promotional materials may include invitations to participate in various activities (such as surveys), events or special offers.

To share with business partners. Where you have expressly consented to this, we may share your information with business partners to permit them to send you marketing communications consistent with your choices. Where we share your information with our related companies, they may use your information, in the same way as we can, under this Privacy Policy.

We do not sell, distribute or otherwise make personal information commercially available to any party, except as described in this Privacy Policy or with your prior permission. We may have to share your personal information with:

A law enforcement agency, or other government agency, is exercising its legal authority and has asked us to provide access to that information;

Our auditors, professional advisers and insurers;

Third parties to whom we may chose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. Any new owner of our business may use your personal information in the same way as set out in this Privacy Policy;

Investigators if the information is required to help identify any abuse or attempt to abuse or compromise the integrity or security of the Sites or any web sites connected to them; or

Another third party if a customer lawfully instructs us to do so.

6. How do we protect your information?

We take the security of the personal information we hold very seriously. Policies and Procedures are in place to safeguard it from loss, misuse and improper disclosure. We use commercially reasonable administrative, technical, personnel and physical measures to safeguard personal information in our control against loss, theft, unauthorized use, disclosure or modification. We also have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so, if you are based in the UK or European Economic Area notification will be made within 72 hours of the breach.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features, in line with the standards set out in under applicable privacy laws, to try to prevent unauthorised access.

We may disclose information to our business partners, customers, service providers and other third party suppliers located overseas for some of the purposes listed above. These overseas entities may be located in United States of America, Singapore, United Kingdom and Japan. Some of the Services are hosted in and managed outside of Australia and in dealing with us, you consent to having any personal information accessible from or transmitted outside of Australia. Cross-border disclosure of personal information by Conexus or our business partners or third-party suppliers will occur in compliance with data transfer requirements of applicable laws and regulations. Where personal information from the European Economic Area or UK is transferred to third-party vendors engaged by us to process such personal information on our behalf who are located in countries that are not recognized by the European Commission as offering an adequate level of personal data protection, such transfers are covered by alternate appropriate safeguards, specifically standard data protection clauses adopted by the European Commission.

8. Direct Marketing

We may send you direct marketing communications and information about our products and services that we consider might be of interest to you. These communications may be sent in various forms, including email, mail and SMS in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). You consent to receiving direct marketing communications and information from us. However, at any time you may opt out of receiving marketing communications from us by contacting us (see details below) or by using opt out facilities provided in the marketing communications and then we will ensure that your name is removed from our mailing list.

9. Your rights?

You have a range of rights over your personal information and we will endeavour to respect any requests to exercise them.

Access. You may request access to the information we hold about you by making a Subject Access Request (SAR) to the Privacy Officer as out lined in section 10 of this Privacy Policy. Once we have confirmed your identity, we will comply with an SAR free of charge within 30 days, unless we deem the request unfounded or excessive. In this event, we will explain why we have decided not to action your request.

Correction. You may request that we correct the information we hold on you when it is incorrect, out of date, or incomplete. Please inform us of any changes to your personal information.

Erasure. You may request that we destroy, delete or discontinue using your personal information when it is no longer necessary for the purpose we originally collected it.

Transfer. You may request the transfer of your personal data to you or a third party.

Restriction. You may request that we stop processing your information when you contest its accuracy or the lawfulness of the processing.

Withdrawing consent. Whenever you have given us your consent to use your information, you have the right to change your mind at any time and withdraw your consent.

Legitimate interests. In cases where we are processing your information on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We will do so unless we believe we have a legitimate overriding reason to continue processing your information.

We will let you know if we cannot delete your personal information or give you access to it for legal or other reasons.

10. How long do we hold your personal Information

You should be aware that we will hold your personal information on our systems for the longest of the following periods:

As long as necessary to maintain our ongoing business relationship, or as needed to provide you with the products, services or information which you are entitled to or can otherwise reasonably expect to receive from us;

For as long as necessary for the purpose for which we collected it or for which you supplied it to us in accordance with any product or service relevant activity or process;

Any retention period that is necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements; or

The end of the period in which litigation or investigations might arise in respect of our business relations or other interactions with you.

Our Privacy Officer will contact you within a reasonable time after receipt of your request or complaint, to discuss your concerns and outline options regarding how they might be resolved.

Complaints. If you think we have breached the Privacy Act or other applicable privacy laws, you may complain to us by contacting us as outlined in this section above. When you contact us, please include your email address, name, address, and telephone number and clearly describe your complaint. We will respond to your complaint as soon as reasonably practicable and in any event within 5 business days, by making contact with you to inform you whether we have accepted your complaint, need further information or do not think we are in breach. We will also inform you of the next steps in resolving your complaint. If you are not satisfied with our response to your complaint, or at any other time, you may refer your complaint to the Office of the Australian Information Commissioner or the applicable supervisory authority for data protection issues.

We may change this privacy policy from time to time and all personal information held by us will be governed by the most recent version of our privacy policy. Any updated versions of this policy will be posted on the Site.